Tagged: appraisal threshold levels

Appraisers Disappointed at Federal Banking Agencies - Appraisers Blogs 21

Appraisers Disappointed at Federal Agencies

I’ve read a number of posts where appraisers are disappointed at federal banking agencies declining to hold public hearings on the topic of raising the appraisal minimum threshold for residential real estate transactions from $250,000 to $400,000. The request for a public hearing on the issue was ‘worth a shot’ but was never a realistic expectation. We knew that when we joined with others in signing the letter. Federal rulemaking agencies already have policies and procedures in place for mandatory public input. It’s unrealistic to expect them to make special exceptions. Especially when existing lobbyists that promoted the short-sighted policy...

Feds Deny Public Hearing - Denial of a Public Hearing is Undemocratic 16

Feds Deny Public Hearing

The Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency have denied  the request for a public hearing on raising the appraisal minimum threshold for residential real estate transactions from $250,000 to $400,000. See the “agencies” rejection letter here. …we do not believe that holding a public hearing would elicit relevant information that could be conveyed through the comment process described above. While the agencies are, therefore, declining your request for a public hearing, we will carefully consider your written comments… The American Society of Appraisers, The Appraisal...

Appraisals Costs Hardly a Burdensome Cost? Appraisers & Realtors Unite! 19

Standing With Us Protecting Consumers!

…average costs and appraisal turnaround times are minimal… VaCAP joins 29 State Appraisal Organizations in opposing an increase in the appraisal threshold. Behind the scenes, VaCAP and the Network have been working with Constantine Cannon LLP on drafting a formal comment on the proposed appraisal threshold increase from $250,000 to $400,000. The result is very thorough and factual. Each state organization contributed facts, figures and scenarios and Constantine Cannon compiled it all referencing current law and prior attempts of increasing the threshold. VaCAP is proud of the work that has been accomplished and proud to be part of a Network...

MCS Valuations (AMC) Closing Shop - ABA Supports Raising De Minimus 18

MCS Valuations (AMC) Closing Shop

I saw a posting by another appraiser on a Facebook page on February 5, 2019 that MCS Valuations, based in Lewisville, TX, is closing shop. They are an AMC, and provide BPO’s and other real estate related services. The appraiser posted a letter from the company. They will not be placing any more appraisal assignments, but are asking appraisers to finish any assigned reports already in the pipeline. What’s really striking about this closure is that in 2014, MCS Valuations bought ‘components’ of CoreLogic’s associated entities that CoreLogic no longer wanted in their business! February 5, 2019 This communication is to inform...

What If the Algorithms Are Wrong? Weapons of Math Destruction... 12

What If the Algorithms Are Wrong?

Algorithms are everywhere… “Algorithms decide who gets a loan, who gets a job interview, who gets insurance and much more — but they don’t automatically make things fair. Mathematician and data scientist Cathy O’Neil coined a term for algorithms that are secret, important and harmful: “weapons of math destruction.” Learn more about the hidden agendas behind the formulas.” “Algorithms are opinions embedded in code. It’s really different from what you think most people think of algorithms. They think algorithms are objective and true and scientific. That’s a marketing trick. It’s also a marketing trick to intimidate you with algorithms, to...

Should We Raise the Appraisal Deminimus Threshold to $2 Million? 7

Should We Raise the Deminimus to $2 Million?

Bank regulators are nearing a decision to raise residential real estate transactions appraisal threshold to $400,000 from $250,000, for certain transactions. Perhaps it should be set to $2 Million, or $5 Million. It strikes me that we have two separate taxpayer regulatory/administrative/quasi-governmental organizations working in opposition. On one hand we have the Appraisal Subcommittee and The Appraisal Foundation (TAF), and 50+ state organizations attempting to regulate, license, and control the education of appraisers. USPAP, (Uniform Standards of Professional Practice) is promulgated by the Appraisal Standards Board (ASB) of the TAF.  USPAP compliance is required for federally related transactions. USPAP comprises two parts:...

AGA Objects De Minimis Increase Proposal - It is Time to Call out the Liars 40

AGA Objects De Minimis Increase Proposal

We object to the proposal to increase the de minimis threshold at which no appraisal is required… Sirs: The American Guild of Appraisers (AGA), of the Office Professional Employees International Union (#44 OPEIU) of the AFL-CIO represents the members and extended family and retirees, taxpayer and consumer real estate appraisal interests of nearly Twelve and a half million citizens and voters. We object to the proposal to increase the de minimis threshold at which no appraisal is required from $250,000 to $400,000. Respectfully, if anything is done with it at all, lowering it to a range not to exceed $100,000...

What Are You Waiting For? Only 179 Comments...Please Comment Now! 13

What Are You Waiting For?

Please comment now! VaCAP sent out a “Call to Action” a month ago to comment on the proposed increase in the appraisal threshold to $400,000. As of this writing, only 179 comments have been received. This is our future, please comment now! Comments must be received by February 5, 2019. The proposed rule would increase the threshold level at or below which appraisals would not be required for residential real estate-related transactions from $250,000 to $400,000.Consistent with the requirement for other transactions that fall below applicable thresholds, regulated institutions would be required to obtain an evaluation of the real property...

Ulterior Motive in Raising De Minimus 20

Ulterior Motive in Raising De Minimus

…raising de minimus shenanigans being promoted… Appraisers, a couple of weeks ago, I sent out a message about a Fee/TT quote conversation I had with an AMC clerk. I received a number of responses from appraisers across this fruited plain who said often they will receive Fee/TT quote requests for the SAME property from MULTIPLE AMC’s. That corroborates stories I hear from appraisers I talk with at conferences. The entire AMC situation is a giant time-wasting game that really doesn’t benefit the borrower at all, and least of all, appraisers. Lenders are the coaches in this game. Another message I received...

Waiving Appraisals, Lowering Appraisal Standards, & Raising De Minimis... 13

Waiving Appraisals & Lowering Appraisal Standards

Freddie getting aggressive in waiving appraisals & promoting appraisal free mortgages… Appraisers, Yes, I have a ‘dog in the fight’ with this article, as I have been an Appraisal Institute member since 2003 (along with other association memberships since). But this article provides explanations about changes to the appraisal process I have not seen elsewhere. Excerpt from “Dodd-Frank rollback weakens appraisal standards“ They started to evaluate whether they wanted to raise that appraisal threshold level from $250,000 to some figure… They left it untouched at $250,000 for residential, but they have increased the commercial real estate appraisal threshold level just in the...

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